Full disclosure defeats suppression: extended limitation cannot be invoked when exemption declarations reveal the manufacturing process.

Full disclosure of the manufacturing process and the use of material in making water storage tanks, together with declarations filed for small-scale exemption and at registration, prevented any finding of suppression or wilful misdeclaration with intent to evade duty. On that factual basis, the extended limitation period under Section 11A could not be invoked, so the demand was held time-barred.

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Issues: Whether the extended period of limitation under Section 11A could be invoked on the ground of suppression or wilful misdeclaration, and whether the demand was time-barred.

Analysis: The respondents had filed declarations for availing small-scale exemption and had disclosed the manufacturing process, including the conversion of material into powder form and its use in manufacture of water storage tanks. These declarations were filed with the revenue and were also furnished at the time of registration of the unit. In view of this disclosure, suppression of facts or wilful misdeclaration with intent to evade duty could not be alleged.

Conclusion: The extended period was not available, the demand was time-barred, and the revenue appeal failed.

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